Motion-Secondary: Yasemin Tekiner in her individual capacity, as a beneficiary and a Trustee of The Yasemin Tekiner 2011 Descendants Trust and derivatively as a holder of equitable interests in a shareholder or a member of the Company Defendants v. Bremen House Inc., German News Company, Inc., Berrin Tekiner, Gonca Tekiner, Billur Akipek in her capacity as a Trustee of the Yasemin Tekiner 2011 Descendants Trust, Zeynep Tekiner (Intervenor Plaintiff)

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                                FILED:         NEW     YORK       COUNTY        CLERK        06/29/2022             09:01        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   605                                                                                RECEIVED      NYSCEF:     06/29/2022




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COMMERCIAL DIVISION, NEW YORK COUNTY

                   YASEMIN TEKINER,
                            in her individual capacity, as a beneficiary
                            and a Trustee of The Yasemin Tekiner
                            2011 Descendants Trust and derivatively as              Index No. 657193/2020
                            a holder of equitable interests in a
                            shareholder or a member of the Company                  Commercial Division Part 3
                            Defendants,
                                                                                    Hon. Joel M. Cohen
                                                                      Plaintiff,
                                                                                    Mot. Seq. No. 24
                                             -against-

                   BREMEN HOUSE INC., BREMEN HOUSE                                              AFFIRMATION OF
                   TEXAS, INC., GERMAN NEWS COMPANY,                                         STEPHEN P. YOUNGER
                   INC., GERMAN NEWS TEXAS, INC., 254-258
                   W. 35TH ST. LLC, BERRIN TEKINER, GONCA
                   TEKINER, and BILLUR AKIPEK, in her capacity
                   as a Trustee of The Yasemin Tekiner 2011
                   Descendants Trust,

                                                                  Defendants.
                   ZEYNEP TEKINER,
                            in her individual capacity, as a beneficiary
                            and a Trustee of The Zeynep Tekiner 2011
                            Descendants Trust and derivatively as a
                            holder of equitable interests in a
                            shareholder or a member of the Company
                            Defendants,

                                                        Intervenor-Plaintiff,

                                             -against-

                   BREMEN HOUSE INC., BREMEN HOUSE
                   TEXAS, INC., GERMAN NEWS COMPANY,
                   INC., GERMAN NEWS TEXAS, INC., 254-258
                   W. 35TH ST. LLC, BERRIN TEKINER, GONCA
                   TEKINER, and BILLUR AKIPEK, in her capacity
                   as a Trustee of The Yasemin Tekiner 2011
                   Descendants Trust,

                                                                  Defendants.


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   FILED:         NEW     YORK       COUNTY        CLERK        06/29/2022             09:01        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   605                                                                                RECEIVED      NYSCEF:     06/29/2022




                           STEPHEN P. YOUNGER, Esq., an attorney duly admitted to practice before the Courts

                  of the State of New York, affirms under the penalty of perjury, pursuant to CPLR § 2106:

                           1.       I am a member of the law firm Foley Hoag LLP, co-counsel for plaintiff Yasemin

                  Tekiner (“Yasemin”) in the above-captioned matter.               I submit this affirmation in further support

                  of Yasemin’s Motion to Remove Defendant Billur Akipek (“Billur”) as Trust Committee Member

                  of my Trust and Appoint an Independent Trust Committee Member (the “Motion”).

                           2.       I am   fully  familiar   with  the  facts  and  circumstances      of this  action,  as  set forth

                  herein, by virtue of my personal involvement as counsel and a review of the case files.

                           3.       On December 22, 2021, I took the deposition of Zeynep Tekiner (“Zeynep”) in this

                  action.    True   and   correct   copies   of  certain   pertinent   portions   of  the  transcript   of  Zeynep’s

                  deposition are attached hereto as Exhibit A.

                           WHEREFORE,           Yasemin     respectfully   requests    that  this Court    grant  her   Motion    and:

                  (1) remove Billur Akipek from Trust Committee for the Yasemin Tekiner 2011 Descendants Trust;

                  (2)  appoint   an  independent     Trust  Committee      member;     and  (3)  grant   Yasemin     such  other   and

                  further relief as may be just and proper.


                  Dated: New York, New York
                           June 29, 2022
                                                                                          Stephen P. Younger




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   FILED:         NEW     YORK       COUNTY        CLERK        06/29/2022             09:01        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   605                                                                                RECEIVED      NYSCEF:     06/29/2022




                            CERTIFICATION PURSUANT TO COMMERCIAL DIVISION RULE 17

                           I hereby certify that the foregoing Affirmation complies with Rule 17 of subdivision (g) of

                  section 202.70 of the Uniform Rules for the Supreme Court and County Court (Rules of Practice

                  for the Commercial Division of the Supreme Court), and has a word count of less than 4,200 words.



                  Dated: New York, New York
                           June 29, 2022
                                                                                          Stephen P. Younger




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